e-invoicing

Compliance Network Implementation Guide

Use case 13: Subcontracting with direct payment or payment delegation

Subcontracting scenario where the end buyer pays the subcontractor directly under payment delegation.

Description

In this use case, a subcontractor sends invoice F1 to the seller or contractor (titulaire). The end buyer (maitre d'ouvrage) pays the subcontractor directly, a practice known as payment delegation under Article 14 of Law No. 75-1334 of 31 December 1975 (Title II) for private contracts.

Two distinct invoices exist in this scenario:

F1

The subcontractor issues this invoice to the contractor for the subcontracted work.

F2

The contractor issues this invoice to the end buyer for the complete project, including subcontracted portions.

The F2 invoice total with VAT (BT-112) covers the full amount. BT-113 (prepaid amount) equals the subcontractor amount to be paid directly, and BT-115 (net amount payable) equals the contractor's own portion.

A direct payment request with the Cross Domain Acknowledgment and Response (CDAR) lifecycle status code 224 may be transmitted from the subcontractor's PA-E to the end buyer's PA-R, with the F1 invoice attached. This informs the end buyer of the direct payment obligation.

Key characteristics
Two invoices

F1 (subcontractor to contractor) and F2 (contractor to end buyer).

F1
  • BG-4 is the subcontractor, BG-7 is the contractor, EXT-FR-FE-BG-02 is the end buyer (as payer).

  • BT-23 is S1 (submission of a service invoice) or S5 (subcontractor sends a service invoice to be directly paid by the end buyer, with tacit approval).

F2

BT-112 is the total with VAT (full project), BT-113 is subcontractor amount paid directly by the end buyer, and BT-115 is the net amount payable to the contractor.

Direct payment request

A direct payment request with the CDAR status code 224, which is required for B2G and recommended for B2B.

Subcontracted work

If subcontracted work qualifies, reverse charge (autoliquidation) with VATEX-FR-AE.

F1 and F2

Payment statuses reference both F1 and F2 for proper tracking.

Relationship to other use cases

Use case 13 extends use case 3 (third-party payer) with construction-specific complexity. The end buyer acts as payer for F1 (similar to use case 3). Use case 14 (co-contracting) is related but involves co-contractors rather than a hierarchical subcontracting relationship. The approval mechanism in use case 14 does not apply to use case 13, where validation is contractual. Use case 8 (factoring) shares the concept of payment redirection but serves a completely different business purpose.

Business and tax context

Legal and regulatory framework

For private contracts (B2B), payment delegation is governed by Article 14 of Law 75-1334. The contractor must validate the subcontractor's invoice, either explicitly or through contractual tacit validation. For construction works subject to reverse charge, the subcontractor uses VATEX-FR-AE with the mention of reverse charge.

Common business scenarios
Construction
The subcontractor performs earthwork, the contractor manages the overall building project.
IT projects
The subcontractor delivers the software component, the contractor manages the system integration.
Infrastructure
Multiple levels of subcontracting in large civil engineering projects.
Tax and accounting implications

If reverse charge applies (construction work between taxable persons), F1 has zero VAT with VATEX-FR-AE. The contractor applies the reverse charge on F1 then declares full VAT on F2. Encaissée (payment received) status management requires coordination. The subcontractor transmits the Encaissée for F1 when paid by the end buyer. The contractor transmits two Encaissée statuses for F2: One for their portion, one for the subcontractor portion paid directly.

Important:

The contractor must attach the direct payment certificates and potentially the F1 invoice to F2 (BG-24). The end buyer uses this documentation to organize split payments to the contractor and the subcontractor.

Key data requirements

Invoice F1 (subcontractor to contractor)
Field ID Description Value
BT-3 Invoice type code 380 (Standard)
BG-4 Seller subcontractor
BG-7 Buyer contractor (titulaire)
EXT-FR-FE-BG-02 Payer End buyer (maitre d'ouvrage)
BT-23 Billing framework S1 or S5
BT-11 Project or lot reference Construction site reference
BT-17 Tender or lot reference
BT-18 Invoiced item, with qualifier in BT-18-1 and a long United Nations Trade Data Interchange Directory (UNTDID) 1153 list
BT-121 VATEX VATEX-FR-AE (if reverse charge)
Invoice F2 (contractor to end buyer)
Field ID Description Value
BT-3 Invoice type code 380
BG-4 Seller contractor (titulaire)
BG-7 Buyer End buyer
BT-112 Total with VAT Full project amount (subcontractor and contractor)
BT-113 Prepaid amount Subcontractor amount (paid directly by the end buyer)
BT-115 Amount due Net amount payable to the contractor
BG-24 Attachments Direct payment attestation, F1 copy

Implementation considerations

Seller considerations
  • The subcontractor must use EXT-FR-FE-BG-02 to designate the end buyer as payer in F1.

  • The subcontractor must include project and site references (BT-11, BT-17, BT-18) for grouping.

  • The contractor must create the F2 with direct payment certificates attached (BG-24).

Buyer considerations
  • The end buyer must process the F2 and the associated direct payment request for F1.

  • Organize split payments to the contractor and the subcontractor.

General considerations
  • The PA-E must support direct payment request (CDAR code 224) creation and transmission.

  • The PA-R must support receiving a direct payment request from a third party, without having the invoice.

Important:

The subcontractor and the Maitre d'Oeuvre (MOE, if applicable) require access to invoices and lifecycle statuses across both F1 and F2. The Sovos solution handles this through its user interface with granular role-based permissions, so subcontractors can track their F1 direct payment status and MOEs can validate invoices across the construction dossier.

SCI mapping
Field SCI path
BT-3 invoice type Invoice/InvoiceTypeCode
BG-4 seller Invoice/AccountingSupplierParty/Party
BG-7 buyer Invoice/AccountingCustomerParty/Party
EXT-FR-FE-BG-02 payer Invoice/PaymentMeans/PaymentMandate/PayerParty
BT-23 billing framework Invoice/InvoicePeriod/DescriptionCode
BT-11 project reference Invoice/ProjectReference/ID
BT-112 total with VAT Invoice/LegalMonetaryTotal/TaxInclusiveAmount
BT-113 prepaid Invoice/LegalMonetaryTotal/PrepaidAmount
BT-115 amount due Invoice/LegalMonetaryTotal/PayableAmount